Govt. of NCT Delhi v. Pradeep Kumar
Background
Several candidates from outside Delhi, belonging to the OBC category, had cleared the Central Teacher Eligibility Test (CTET) using a 5% relaxation in qualifying marks available to OBC candidates in their home states, and then applied for Special Education Teacher vacancies in Delhi. Since they did not hold a Delhi-issued OBC certificate, they could not claim OBC-reserved seats in Delhi, so they instead sought appointment against unreserved (general) category vacancies based on their rank in the merit list. The Central Administrative Tribunal and the Delhi High Court both ruled in the candidates' favour, relying on an earlier Supreme Court decision (Vikas Sankhala) permitting similar migration to the general category.
Decision Breakdown
The Supreme Court held that the Vikas Sankhala precedent did not apply here because, unlike in that Rajasthan case, there was no mechanism in the Delhi recruitment that neutralised the advantage gained from relaxed CTET pass marks, and government office memoranda expressly state that candidates selected under any relaxed standard (including in qualification) must be counted against reserved vacancies only, not general ones. Since the respondents had cleared the CTET with marks below the 60% required for unreserved-category eligibility, and they held no valid OBC certification recognised by the Delhi government, they were not eligible for either the OBC quota or the general category in Delhi. The Court set aside the High Court's judgment and allowed the government's appeal, holding that allowing such migration would dilute merit standards in the unreserved category.
Lesson Learnt
A qualification obtained using a relaxed standard meant for a reserved category (such as lower pass marks) cannot later be used to compete for general/unreserved category vacancies: reservation-based relaxations and open-category eligibility operate on different standards that cannot be mixed, even if an applicant otherwise scores well in the final test.